Taxation of independent personal services may be allocated to source state where fixed base or prolonged stay applies. Income from independent personal services by a resident is taxable only in the residence State except where the individual has a fixed base in the other State (only income attributable to that fixed base may be taxed there) or where the individual's aggregate stay in the other State meets the relevant threshold (only income from activities performed there may be taxed there).
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of independent personal services may be allocated to source state where fixed base or prolonged stay applies.
Income from independent personal services by a resident is taxable only in the residence State except where the individual has a fixed base in the other State (only income attributable to that fixed base may be taxed there) or where the individual's aggregate stay in the other State meets the relevant threshold (only income from activities performed there may be taxed there).
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